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Report of the Meeting of the National Advisory Committee on Institutional Quality
and Integrity
June 25-26, 2012
/s/
Jamienne S. Studley, Chair
2
Report of the Meeting
of the
National Advisory Committee
on Institutional Quality and Integrity
June 25-26, 2012
Jamienne S. Studley, Chair
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY .................................................................................................................. 5
SUMMARY OF AGENCY-RELATED ACTIONS TAKEN BY THE ADVISORY COMMITTEE
I. Petitions for Renewal of Recognition as Nationally Recognized Accrediting Agencies including
any Expansion/Contraction or Revision in the Scope of Recognition as Currently Written.
A. Accreditation Commission for Midwifery Education (ACME)………………………………..6
B. Accreditation Council for Pharmacy Education (ACPE)……………………………….……...7
C. American Dental Association, Commission on Dental Association (ADA)………....………...8
D. American Occupational Therapy Association, Accreditation Council for
Occupational Therapy Education (AOTA)………………………………… …………………9
E. Association for Biblical Higher Education (ABHE)………………………………..….…........10
F. Association for Clinical Pastoral Education, Inc. (ACPEI)……………………………….........11
G. Commission on Collegiate Nursing Education (CCNE)……………………………………….13
H. Distance Education and Training Council (DETC)…………………………………………….14
I. Middle States Commission on Secondary Schools (MSCSS)………………………………….15
J. National League for Nursing Accrediting Commission, Inc. (NLNAC)………………………..16
K. Southern Association of Colleges and Schools, Commission on Colleges (SACSCOC) ……..18
3
II. Renewal of Recognition as Nationally Recognized Accrediting Agencies Based on Review of the
Agency’s Compliance Report
A. Council on Academic Accreditation in Audiology and Speech-Language
Pathology of the American Speech-Language-hearing Association (ASLHA)………........19
B. National Accrediting Commission of Career Arts & Sciences, Inc. (NACCAS)………….19
III. Petition for Renewal of Recognition of a State Agency Recognized for the
Approval of Public Postsecondary Vocational Education
Puerto Rico State Agency..…………………………………………………………...……….20
SUMMARY OF OTHER ACTIONS TAKEN BY THE ADVISORY COMMITTEE
I. Request for Degree-Granting Authority by a Federal Institution to award a Degree
National Intelligence University (NIU)……..…………………………………………………22
4
DISCLAIMER
This report was written as a part of the activities of the National Advisory
Committee on Institutional Quality and Integrity (NACIQI), an independent
advisory committee established by statute. The NACIQI is subject to the Federal
Advisory Committee Act and the regulations implementing that statute. This
report represents the views of the NACIQI. The report has not been reviewed for
approval by the Department of Education, and therefore, the report’s
recommendations do not purport to represent the views of the Department.
5
EXECUTIVE SUMMARY
Background:
The National Advisory Committee on Institutional Quality and Integrity (NACIQI or the Committee),
was established by Section 114 of the Higher Education Act (HEA) of 1965, as amended by the Higher
Education Amendments of 1992 and, most recently, Section 106 of the Higher Education Opportunity
Act (HEOA). Chief among its statutory functions is the Committee’s responsibility to advise the
Secretary of Education, or his designee, the Senior Department Official (the Assistant Secretary for
Postsecondary Education), regarding the recognition of specific accrediting agencies or associations, or
specific State approval agencies, as reliable authorities concerning the quality of education and training
offered by the postsecondary educational institutions and programs they accredit. Another function of
the NACIQI is to advise the Secretary on the establishment and enforcement of the Criteria for
Recognition of accrediting agencies or associations under Subpart 2, Part H, Title IV, of the HEA. The
NACIQI also provides advice to the Secretary regarding policy affecting both recognition of accrediting
and State approval agencies and institutional eligibility for participation in programs authorized under
Title IV of the Higher Education Act of 1965, as amended. The NACIQI is required by law to meet at
least twice a year.
The HEOA made changes to section 496 of the HEA “Recognition of Accrediting Agency or
Association” and suspended the activities of the NACIQI upon enactment on August 14, 2008. It also
changed the composition of the Committee by increasing the membership from 15 to 18 and shifting
appointment authority that had been vested solely in the Secretary to the Secretary, the President pro
tempore of the Senate, and the Speaker of the House, each of whom may appoint six members. Also,
rather than having the Secretary appoint the Chair, the HEOA required the members to elect a Chair. In
July 2010, new regulations went into effect that govern the process by which accrediting agencies seek
recognition by the Secretary as a reliable authority regarding the quality of education and training
provided by an institution (or program) they accredit.
Discussion:
At its June 25-26, 2012 meeting, held at the Westin-Alexandra Hotel in Alexandria, Virginia, the
Committee met to carry out its duties to advise the Assistant Secretary with respect to the recognition of
accrediting agencies and State approval agencies and to advise the Secretary on a request for degree-
granting authority by a federal entity.
NACIQI members in attendance for all or part of the meeting included Jamienne S. Studley (Chair),
Arthur J. Rothkopf (Vice Chair), Jill Derby, George T. French, Jr., Arthur Keiser, William “Brit”
Kirwan, Earl Lewis, Dr. William Pepicello, Susan D. Phillips, Cameron C. Staples, Carolyn G.
Williams, and Frank H. Wu.
U.S. Department of Education personnel who participated in the meeting included: Committee
Executive Director Carol Griffiths, Accreditation Director Kay Gilcher, Program Attorney Sarah
Wanner, Office of Postsecondary Education staff: Herman Bounds, Elizabeth Daggett, Karen Duke,
Jennifer Hong-Silwany, Patricia Howes, Charles Mula, Steve Porcelli, Cathy Sheffield, and Rachael
Shultz.
6
THE RECOGNITION OF ACCREDITING AGENCIES AND STATE APPROVAL AGENCIES:
The Committee reviewed petitions and reports from 14 agencies – 13 accrediting agencies and one State
approval agency.
Summary of Agency-Related Actions Taken by the Committee:
I. Petitions for Renewal of Recognition as Nationally Recognized Accrediting Agencies including
any Expansion/Contraction or Revision in the Scope of Recognition as Currently Written.
A. Accreditation Commission for Midwifery Education (ACME)
Action for Consideration: Petition for Renewal of Recognition.
Current Scope of Recognition: The accreditation and pre-accreditation of basic certificate, basic
graduate nurse-midwifery, direct entry midwifery, and pre-certification nurse-midwifery education
programs. The accreditation and pre-accreditation of freestanding institutions of midwifery
education that may offer other related health care programs to include nurse practitioner programs,
and including those institutions and programs that offer distance education.
Requested Scope of Recognition: The accreditation and pre-accreditation of basic certificate,
basic graduate nurse-midwifery, direct entry midwifery, and pre-certification nurse-midwifery
education programs, including those programs that offer distance education.
Committee Recommendation: Vote of 10-0 (Recusal: E. Lewis)
Recommend that the ACME’s recognition be continued to permit the agency an opportunity to
within a 12-month period bring itself into compliance with the criteria cited in the staff report and
that it submit for review within 30 days thereafter, a compliance report demonstrating compliance
with the cited criteria and their effective application. Such continuation shall be effective until the
Department reaches a final decision. Further recommend that the Assistant Secretary revise the
accrediting agency's scope of recognition as requested.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
The above issues focus primarily on the agency’s need to complete policy modifications or to
provide additional documentation in two areas of the criteria -- in the area of organizational and
administration requirements and in the area of required standards and their application. More
specifically the agency needs to provide additional information regarding the training of its
§602.15(a)(2) §602.15(a)(5) §602.16(a)(1)(i)
§602.16(a)(1)(vii) §602.16(a)(1)(ix) §602.17(f)
§602.19(b) §602.19(c) §602.20(a)
§602.20(b)
7
reviewers and decision-makers and documentation that its boards and appeals panels are in
compliance with respect to the definition of a public member and to provide information and
documentation regarding its criterion on recruiting, academic calendars and catalogs, its
consideration of student complaints, fiscal information, program performance with respect to
student achievement, and review of variations in enrollment. It must also clarify its policy
regarding compliance timeframes and provide additional information and documentation
regarding extensions for good cause.
The Committee had no questions for staff. Committee discussion of the agency’s petition focused
on seeking and receiving assurance that the single institution impacted by the agency’s request for
a contraction of its scope of recognition to no longer accredit institutions has another alternative
for accreditation. The Committee also engaged the agency in a discussion of how it ensures the
continued appropriateness of its student learning outcome measures, the relationship of exam
passage scores to the quality of the practitioner, and the growth in and agency monitoring of
midwifery programs.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. William Kirwan
Representatives of the Agency:
Dr. Susan Stone, Chair, ACME
Dr. Sally Tom, Commissioner, ACME
Ms. Carol Gisselquist, Commissioner, ACME
Ms. Jo Ann Burke, Administrative Assistant, ACME
B. Accreditation Council for Pharmacy Education (ACPE)
Action for Consideration: Petition for Renewal Recognition.
Current and Requested Scope of Recognition: The accreditation and preaccreditation, within the
United States, of professional degree programs in pharmacy leading to the degree of Doctor of
Pharmacy, including those programs offered via distance education.
Committee Recommendation: Vote of 10-0 (Recusal: W. Kirwan)
Recommend the continued recognition of ACPE and require the agency to come into compliance
within 12 months, and submit a compliance report to demonstrate the agency’s compliance with
the issues identified.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
8
§602.15(a)(2) §602.16(a)(1)(ix) §602.16(a)(2)
§602.26(b) §602.26(d) §602.26(e)
§602.28(b) §602.28(d) §602.28(e)
The issues identified above, include training for the appeals panels; review of the record of student
complaints; clarity in publicly distinguishing unaccredited programs at schools with both
accredited and unaccredited pharmacy programs; the agency's notification practices; and the
agency's handling of adverse decisions.
The Committee requested that the Department staff analyst provide an oral summary of his
observation of the agency’s on-site review process. Committee discussion focused on the
relationship of the agency with other professional organizations, its implementation and
assessment of its standardized surveys, and how the agency uses aggregated student learning
outcome data and peer cohorts in its comprehensive review of programs for accreditation.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. George T. French
Mr. Arthur J. Rothkopf, J.D.
Representatives of the Agency:
Dr. Robert S. Beardsley, President, ACPE Board of Directors and Professor,
University of Maryland School of Pharmacy
Dr. Peter H. Vlasses, Executive Director, ACPE
Dr. Jeffrey W. Wadelin, Associate Executive Director, and Director, Professional
Degree, ACPE
Dr. J. Gregory Boyer, Assistant Executive Director and Assistant Director,
Professional Degree Program Accreditation, ACPE
C. American Dental Association, Commission on Dental Association (ADA)
Action for Consideration: Petition for Renewal of Recognition.
Current and Requested Scope of Recognition: The accreditation of predoctoral dental education
programs (leading to the D.D.S. or D.M.D. degree), advanced dental education programs, and
allied dental education programs that are fully operational or have attained "Initial Accreditation"
status, including programs offered via distance education.
Committee Recommendation: Vote of 10-0 (Recusal: W. Kirwan)
Recommend that the CODA recognition be continued, permit the agency an opportunity to within
a 12 month period bring itself into compliance with the criteria cited in the staff report, and that it
submit for review within 30 days thereafter, a compliance report demonstrating compliance with
9
the cited criteria and their effective application. Such continuation shall be effective until the
Department reaches a final decision.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
The issues identified above, are in the regulatory sections addressing an organization’s
administrative procedures and its standards and their application. Specifically, they focus on
inconsistency across documents re the agency’s conflict of interest policy, documentation of its
application of its revised site visit evaluation reports, and its expanded feedback to its programs
regarding its performance relative to student achievement.
The Committee requested that the Department staff analyst provide an oral summary of his
observation of the agency’s on-site review process. Committee discussion focused on the issue
raised by the third party commenter that there is inadequate dental hygienist representation on the
decision-making body and, after questioning the agency representatives, expressed concern that
the agency should be more concerned about the level of representation in the peer review process.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. Jill Derby
Mr. Arthur J. Rothkopf, J.D.
Representatives of the Agency:
Dr. Steven Tonelli, Chair, CODA
Dr. Kent Knoernschild, Vice Chair, CODA
Ms. Cathryn Albrecht, Legal Counsel
Dr. Anthony Ziebert, Interim Director, CODA
Third-Party Oral Comment:
Dr. Denise Bowers, RDN, President-Elect, American Dental Hygienists Association
D. American Occupational Therapy Association, Accreditation Council for Occupational
Therapy Education (AOTA)
Action for Consideration: Petition for Renewal of Recognition.
Current and Requested Scope of Recognition: The accreditation of occupational therapy
educational programs offering the professional master's degree, combined baccalaureate/master's
degree, and occupational therapy doctorate (OTD) degree; the accreditation of occupational
§602.15(a)(6)
§602.16(a)(1)(ix)
§602.17(f)
10
therapy assistant programs offering the associate degree or a certificate; and the accreditation of
these programs offered via distance education.
Committee Recommendation: Vote of 11-0
Accept the Consent Agenda. [NOTE: The Consent Calendar contained the specific
recommendation to renew the agency’s recognition for a period of five years.]
Comments: There were no compliance issues and no further discussion of the agency’s petition.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Reader:
Dr. Susan Phillips
Dr. Carolyn G. Williams
Representatives of the Agency:
Dr. Letha J. Mosely, Chair, ACOTE
Dr. Ellen McLaughlin, Chair Elect, AOTA
Dr. Neil Harvison, Director, Accreditation and Academic Affairs, AOTA
E. Association for Biblical Higher Education (ABHE)
Action for Consideration: Petition for Renewal of Recognition
Current Scope of Recognition: The accreditation and preaccreditation ("Candidate for
Accreditation") of Bible colleges and institutes in the United States offering undergraduate
programs through both campus-based instruction and distance education.
Requested Scope of Recognition: The accreditation and preaccreditation (“Candidate for
Accreditation”), at the undergraduate level, of institutions of biblical higher education in the
United States offering both campus-based and distance education instructional programs.
Committee Recommendation: Vote of 10-0
Recommend that the ABHE recognition be continued to permit the agency an opportunity to
within a 12 month period bring itself into compliance with the criteria cited in the staff report and
that it submit for review within 30 days thereafter, a compliance report demonstrating compliance
with the cited criteria and their effective application. Such continuation shall be effective until the
Department reaches a final decision.
Further recommend that the Assistant Secretary revise the accrediting agency’s scope of
recognition as requested.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
11
§602.14(a) §602.14(b) §602.14(c) §602.15(a)(2)
§602.15(a)(6) §602.16(a)(1)(i) §602.16(a)(1)(ix) §602.17(c)
§602.19(d) §602.20(a) §602.20(b) §602.21(a)(b)
§602.21(c) §602.22(b) §602.22(c)(1) §602.22(c)(2)
§602.24(e) §602.24(f)(3) §602.24(f)(4)
The issues identified above, are in the areas of organizational and administrative requirements;
required standards and their application; and required operating policies and procedures. The
issues concern the agency's conflict of interest policy; appeals panel selection and training; student
achievement and student complaint standards; joint accreditation review policies and procedures;
enforcement timelines and actions' standards review process; substantive change policies and
procedures; transfer of credit policy; and credit hour deficiencies and notifications. Most of the
outstanding issues require a demonstration of implementation of policy revisions.
The Committee noted the agency has already begun to address its compliance issues and a brief
discussion focused on the agency’s organizational structure and the frequency with which ABHE
policymakers meet. The Committee also sought additional information from the agency on the
benefits of the agency’s accreditation of Canadian institutions.
The Committee also questioned what the Department staff is doing to provide agencies with
training or other pre-recognition awareness before submitting their petitions.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. George T. French
Dr. William Pepicello
Representatives of the Agency:
Dr. Ronald C. Kroll, Director, Commission on Accreditation, ABHE
Dr. Clay A. Ham, Chair, Commission on Accreditation, ABHE
Dr. Randall E. Bell, Director Emeritus, Commission on Accreditation, ABHE
F. Association for Clinical Pastoral Education, Inc. (ACPEI)
Action for Consideration: Petition for Renewal of Recognition
Current and Requested Scope of Recognition: The accreditation of both clinical pastoral education
(CPE) centers and Supervisory CPE programs located within the United States and territories.
Advisory Committee Recommendation: Vote 9-1
Recommend that the ACPEI’s recognition to be continued to permit the agency an opportunity to
within a12 month period bring itself into compliance with the criteria cited in the staff report and
12
that it submit for review within 30 days thereafter, a compliance report demonstrating compliance
with the cited criteria and their effective application. Such continuation shall be effective until the
Department reaches a final decision.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
§602.15(a)(1) §602.15(a)(2) §602.15(a)(4) §602.15(b)
§602.16(a)(1)(i) §602.16(a)(1)(iv) §602.16(a)(1)(vi) §602.19(a)
§602.19(c) §602.20(b) §602.23(a) §602.25(f)
§602.26(a) §602.26(b) §602.26(c) §602.26(d)
§602.26(e)
The issues identified above, include organizational and administrative requirements; required
standards and their applications; and required operating policies and procedures. More
specifically, the outstanding issues consist primarily of the need for documentation regarding the
agency's application of policies, as well as evidence of final revisions to policies in accordance
with the response to the staff analysis. One issue of concern to the Committee, for example, is that
the agency is not assessing student outcomes. The agency stated that it uses only program
completion as its measure of student achievement and that even this was not sufficiently reported.
Of particular concern to the Committee is the issue of the adequacy of agency staffing levels to
carry out all required accreditation functions to the level expected of a recognized agency. The
Committee engaged the agency in lengthy discussion of how it provides accreditation reviews to
its 400+ centers with only one full-time employee as well as voiced concern for the significant
policy revisions necessary to comply with the regulatory criteria. As a result of continued
concern of some Committee members, an amendment was proposed to the initial motion to limit
the agency’s recognition and to not include any new accreditations under the recognition and to
not place the agency on the Consent Calendar when its compliance report is reviewed. After
discussion, it failed to be seconded.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. Susan Phillips
Mr. Cameron C. Staples, J.D.
Representative of the Agency:
Reverend Deryck Durston, Interim Executive Director, ACPEI
13
G. Commission on Collegiate Nursing Education (CCNE)
Action for Consideration: Petition for Renewal of Recognition and Expansion of Scope to include
the agency’s accreditation of nursing education programs at the doctoral level.
Current Scope of Recognition: The accreditation of nursing education programs in the United
States, at the baccalaureate and graduate degree levels, including programs offering distance
education.
Requested Scope of Recognition: The accreditation of nursing education programs in the United
States, at the baccalaureate, masters, and doctoral levels, including programs offering distance
education.
Advisory Committee Recommendation #1: Vote 7-1 (Recusals: E. Lewis, W. Pepicello)
Recommend that the CCNE recognition be renewed for 5 years and that the agency clarifies with
Department staff how agency-and program-identified student achievement thresholds are reviewed
in the site visit process.
Advisory Committee Recommendation #2: Vote 8-0 (Recusals: E. Lewis, W. Pepicello)
Further recommend that the Assistant Secretary revises the accrediting agency's scope of
recognition as requested [an expansion of scope to include the accreditation of doctoral programs].
Comments: After extensive discussion with the agency concerning their student achievement
requirements (the singular criterion cited by the Department staff), the Committee found the
agency to be operating in full compliance with the criteria for recognition. The Committee was
not convinced by the Department’s position that first cited the issue to be that the agency
standards did not include numeric student outcomes thresholds, and subsequently noted that the
agency site team reports did not reflect the site teams’ assessment of program identified student
achievement goals. The Committee’s review concluded that the agency’s accreditation processes
and documentation exhibit multiple points of agency review of measureable student achievement
thresholds throughout the accreditation cycle; and that these are sufficient to demonstrate more
than a threshold compliance with the criterion -- without being prescriptive in directing the agency
as to what its standards must include.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. Susan D. Phillips
Representatives of the Agency:
Dr. Jennifer Butlin, Executive Director, CCNE
Dr. Linda Caldwell, Chair, Board of Commissioners
Dr. Geraldine Bednash, Chief Executive Officer and Executive director, American Association of
Colleges of Nursing
14
H. Distance Education and Training Council (DETC)
Action for Consideration: Petition for Renewal of Recognition
Current Scope of Recognition: The accreditation of postsecondary institutions in the United States
that offer degree programs primarily by the distance education method up to and including the
professional doctoral degree, and are specifically certified by the agency as accredited for Title IV
purposes; and for the accreditation of postsecondary institutions in the United States not
participating in Title IV that offer programs primarily by the distance education method up
through the professional doctoral degrees.
Requested Scope of Recognition: The accreditation of postsecondary institutions in the United
States that offer degree programs primarily by distance education up through professional doctoral
degrees, and are specifically certified by the agency as accredited for Title IV purposes; and for
the accreditation of postsecondary institutions in the United States not participating in Title IV that
offer programs primarily by distance education or correspondence education up through
professional doctoral degrees.
Advisory Committee Recommendation: Vote 10-0 (Recusal: A. Keiser)
Recommend that the DETC recognition be continued to permit the agency an opportunity to
within a 12 month period bring itself into compliance with the criterion on notification cited in the
staff report and that it submit for review within 30 days thereafter, a compliance report
demonstrating compliance with the criterion and its effective application. Such continuation shall
be effective until the Department reaches a final decision.
Further recommend that the Assistant Secretary revise the accrediting agency’s scope of
recognition as requested.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issue listed below. It is 34 C.F.R.
§602.26(b)
Though the Department staff cited the agency on two criteria -- one an issue of credit hour policy
and the other an issue of agency notifications of its final adverse actions, Committee review of the
credit hour issue concludes that the issue is a timing issue and not a compliance issue. The
singular compliance issue of concern to the Committee is that the agency needs to document its
final adverse action notifications.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. William Pepicello
Representatives of the Agency:
15
Dr. Michael P. Lambert, Executive Director, DETC
Dr. Tim Mott, Chair, DETC Accrediting Commission
Dr. Elise Scanlon, Legal Counsel
I. Middle States Commission on Secondary Schools (MSCSS)
Action for Consideration: Petition for Renewal of Recognition
Current and Requested Scope of Recognition: The accreditation of institutions with
postsecondary, non-degree granting career and technology programs in Delaware, Maryland, New
Jersey, New York, Pennsylvania, the Commonwealth of Puerto Rico, the District of Columbia,
and the U.S. Virgin Islands to include the accreditation of postsecondary, non-degree granting
institutions that offer all or part of their educational programs via distance education modalities.
Advisory Committee Recommendation: Vote 9-2
Recommend that the MSCSS’s recognition be continued to permit the agency an opportunity to
within 12 months period bring itself into compliance with the criteria cited in the staff report and
that it submit for review within 30 days thereafter, a compliance report demonstrating compliance
with the cited criteria and their effective application.
Further move that based upon concerns raised by the NACIQI a limitation be imposed on the
agency to not recognize new accreditation granted to any institution and/or program. Such
continuation and limitation shall be effective until the Department reaches a final decision.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
The issues identified above, crosscut all sections of the criteria for recognition, to include
organizational and administrative requirements; required standards and their applications; and
required operating policies and procedures. Of particular concern to the Committee are the
agency’s financial capabilities, its staffing levels, and overall perceptions of inadequate attention
§602.15(a)(1) §602.16(a)(1)(iii) §602.16(a)(1)(vii) §602.16(a)(1)(ix)
§602.16(a)(1)(x) §602.16(b)(c) §602.17(g) §602.19(b)
§602.19(d) §602.20(a) §602.20(b) §602.22(a)(1)
§602.22(a)(2)(i-vii) §602.22(a)(2)(ix-x) §602.22(a)(3) §602.22(b)
§602.22(c) §602.22(c)(1) §602.22(c)(2) §602.22(c)(3)
§602.22(d) §602.23(c) §602.23(d) §602.23(e)
§602.24(a) §602.24(b) §602.24(c)(1) §602.24(c)(2)
§602.24(c)(3) §602.24(c)(5) §602.24(d) §602.24(e)
§602.24(f)(2) §602.24(f)(3) §602.24(f)(4) §602.25(h)
§602.26(a) §602.26(b) §602.26(c) §602.26(d)
§602.26(e) §602.27(a)(1-5) §602.27(a)(6-7)(b) §602.28(b)
§602.28(c) §602.28(d) §602.28(e)
16
by the agency to developing a petition that addressed the criteria and its unresponsiveness to the
issues raised in the draft staff analysis.
The Committee engaged the agency in extensive discussion of its financial reporting, the adequacy
of its revenues to support its accrediting activities, and its budgeting as reflected on the financial
documents. The Committee also questioned the agency regarding its concern that the agency did
not place sufficient effort on its petition and response to the draft analysis calling into question the
adequacy of the agency’s staffing levels (at best) or inability to document any application of its
policies and procedures. Based on the agency representatives’ responses, prior to its motion, the
Committee discussed at length its options for making a recommendation to the Assistant Secretary
and the consequences of various options. While the Committee shared the conclusion of the
Department staff that the agency could be expected to demonstrate compliance with the criteria for
recognition within the 12 months allowed by statute, the Committee’s concerns for the agency’s
condition, were such that the Committee further determined that a limitation on the agency’s
recognition (to not recognize any new institution/program accreditations) was necessary.
In addition to the recommendation, the Committee was explicit in requesting that staff provide an
oral report at the next meeting on the agency’s perceived progress.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. Arthur E. Keiser
Dr. Carolyn G. Williams
Representatives of the Agency:
Dr. Thomas J. Bistocchi, Chair, MSCSS
Dr. Henry G. Cram, Jr., President, Middle States Commission on Elementary and Secondary
Schools (MSCESS)
Dr. Kenneth D. Kastle, Chief of Staff, MSCESS
J. National League for Nursing Accrediting Commission, Inc. (NLNAC)
Action for Consideration: Petition for Renewal of Recognition and an Expansion of Scope to
include the agency’s accreditation of nursing education program offering the clinical doctorate
degree.
Current Scope of Recognition: The accreditation in the United States of programs in practical
nursing, and diploma, associate, baccalaureate and higher degree nurse education programs,
including those offered via distance education.
Requested Scope of Recognition: Accreditation of nursing education programs and schools, both
postsecondary and higher degree, which offer a certificate, diploma, or a recognized professional
degree including clinical doctorate, masters, baccalaureate, associate, diploma, and practical
nursing programs in the United States and its territories, including those offered via distance
education.
17
Advisory Committee Recommendation: Vote 9-0 (Recusal: A. Keiser)
Recommend that the NLNAC recognition be continued to permit the agency an opportunity to
within a 12 month period bring itself into compliance with the criteria cited in the staff report and
that it submit for review within 30 days thereafter, a compliance report demonstrating compliance
with the cited criteria and their effective application. Such continuation shall be effective until the
Department reaches a final decision.
Further recommend that the Assistant Secretary grant the agency's request for an expansion of its
scope of recognition to include the accreditation of clinical doctorate educational programs.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
§602.14(a) §602.14(b)
§602.15(a)(2) §602.16(b)(c)
§602.22(a)(3) §602.26(d)
The above issues focus primarily on the need for the agency to provide greater documentation
demonstrating the application of its policies and procedures regarding the training it provides for
public representatives serving on its appeal panel; its definition of distance education; its
substantive change policy defining the circumstances under which it would cause it to require a
program to undergo a new comprehensive evaluation; and its accreditation action notification
policies and procedures.
Of particular concern to the Committee and the focus of its deliberation was on the issue of the
degree of “separateness and independence” of the recognized accreditation Commission from the
trade association National League for Nursing (NLN). The two entities are embroiled in multiple
litigations at this time to resolve/dissolve their relationship. After a discussion that updated the
Committee on the status of the litigations, in the words of one Committee member, “this
body[NACIQI] is not in a position to sort out the legal dispute between NLN, on the one hand,
and the accrediting authority, on the other hand, and until that's resolved, nothing more can be
done. The agency agrees with the staff, and the two primary readers do as well, that under the
current relationship of these entities, there is not compliance with the separate and independent
requirement.”
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis and report.
NACIQI Primary Readers:
Mr. Cameron C. Staples, J.D.
Mr. Frank H. Wu, J.D.
Representatives of the Agency:
Dr. Sharon Tanner, CEO, NLNAC
Dr. Elizabeth Mahaffey, Chair, NLNAC Board of Commissioners
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Mr. Patrick McKee, Legal Counsel
K. Southern Association of Colleges and Schools (SACSCOC)
Action for Consideration: Petition for Renewal of Recognition
Current Scope of Recognition: The accreditation and preaccreditation ("Candidate for
Accreditation") of degree-granting institutions of higher education in Alabama, Florida, Georgia,
Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and
Virginia, including distance education programs offered at those institutions.
Requested Scope of Recognition: The accreditation and preaccreditation (“Candidate for
Accreditation”) of degree-granting institutions of higher education in Alabama, Florida, Georgia,
Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and
Virginia, including the accreditation of programs offered via distance and correspondence
education within these institutions. This recognition extends to the SACSCOC Board of Trustees
and the Appeals Committee of the College Delegate Assembly on cases of initial candidacy or
initial accreditation and for continued accreditation or candidacy.
Advisory Committee Recommendation: Vote 8-0 (Recusals: G. French, A. Keiser, E. Lewis)
Recommend that the SACSCOC recognition be continued to permit the agency an opportunity to
within a 12 month period bring itself into compliance with the criteria cited in the staff report and
that it submit for review within 30 days thereafter, a compliance report demonstrating compliance
with the cited criteria and their effective application. Such continuation shall be effective until the
Department reaches a final decision.
Further recommend that the Assistant Secretary revise the accrediting agency’s scope of
recognition as requested.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
The Committee had no questions for Department staff. The Committee’s deliberation included
questions directed to the agency on the issues raised by the third party commenters, particularly
with respect to the allegations of potential conflict of interest; the agency’s process for reviewing
complaints it receives; the agency’s definition of collegiate standards; and its application of its
student learning outcome standards.
NACIQI Primary Readers:
Dr. Jill Derby
Mr. Frank H. Wu, J.D.
§602.16(a)(1)(i) §602.16(a)(1)(ii)
§602.17(f) §602.22(a)(2)(ix-x)
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Representatives of the Agency:
Dr. John Hilpert, Chair, SACSCOC Board of Trustees
Dr. Larry Earvin, Vice Chair, SACSCOC Board of Trustees
Dr. Belle Wheelan, President, SACSCOC
Ms. Carol Luthman, Director of Institutional Support, SACSCOC
II. Renewal of Recognition as Nationally Recognized Accrediting Agencies Based on Review of
the Agency’s Compliance Report
A. Council on Academic Accreditation in Audiology and Speech-Language
Pathology of the American Speech-Language-Hearing Association (ASLHA)
Action for Consideration: Renewal of Recognition after Review of the Compliance Report
Current and Requested Scope of Recognition: The accreditation and preaccreditation
(Accreditation Candidate) throughout the United States of education programs in audiology and
speech-language pathology leading to the first professional or clinical degree at the master’s or
doctoral level, and the accreditation of these programs offered via distance education.
Committee Recommendation: Vote of 11-0
Accept the Consent Agenda. [NOTE: The Consent Calendar contained the specific
recommendation to accept the agency’s compliance report and to renew the agency’s recognition
for a period of four years.]
Comments: There were no compliance issues and no further discussion of the agency’s report.
Written Materials Reviewed by the Committee: Compliance report and supporting documentation
submitted by the agency, and the Department staff analysis and report.
NACIQI Primary Reader:
Dr. Earl Lewis
Representatives of the Agency:
Ms. Patrima Tice, Director of Accreditation, ASHA
Ms. Tess Kirsch, Associate Director of Accreditation for Policy and Education, ASHA
B. National Accrediting Commission of Career Arts & Sciences, Inc. (NACCAS)
Action for Consideration: Renewal of Recognition after Review of the Compliance Report
Current and Requested Scope of Recognition: The accreditation throughout the United States of
postsecondary schools and departments of cosmetology arts and sciences and massage therapy.
Committee Recommendation: Vote of 11-0
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Accept the Consent Agenda. [NOTE: The Consent Calendar contained the specific
recommendation to accept the agency’s compliance report and to renew the agency’s recognition
for a period of four years.]
Comments: There were no compliance issues and no further discussion of the agency’s report.
Written Materials Reviewed by the Committee: Compliance report and supporting documentation
submitted by the agency, and the Department staff analysis and report.
NACIQI Primary Readers:
Dr. William Pepicello
Representatives of the Agency:
Dr. Tony Mirando, Executive Director, NACCAS
Mr. Darin Wallace, Esq., Director of Government Affairs and Legal, NACCAS
III. Petitions for Renewal of Recognition State Agencies Recognized for the
Approval of Public Postsecondary Vocational Education
A. Puerto Rico State Agency
Action for Consideration: Petition for Renewal of Recognition as a State Approval Agency.
Current Scope of Recognition: State agency for the approval of public postsecondary vocational
education.
Advisory Committee Recommendation: Vote 9-2
Recommend that the Puerto Rico State Agency does not comply with the criteria for recognition
and that there is sufficient evidence that the agency cannot reasonably be expected to bring itself
into compliance in a timely manner and therefore the agency’s petition for renewal of recognition
be denied.
Comments: The Committee found the agency to be operating in compliance with the criteria for
recognition, except for the issues listed below. They include 34 C.F.R.
§603.24(a)(1)(iii) §603.24(a)(2)(ii) §603.24(a)(2)(iii)(A)
§603.24(a)(2)(iii)(B) §603.24(a)(2)(iii)(C) §603.24(a)(3)(i)
§603.24(a)(3)(ii)(A) §603.24(a)(3)(ii)(B) §603.24(a)(3)(iii)
§603.24(b)(1)(i) §603.24(b)(1)(iii) §603.24(b)(1)(iv)
§603.24(b)(1)(v) §603.24(b)(1)(vi) §603.24(b)(1)(vii)
§603.24(b)(1)(viii) §603.24(b)(1)(ix) §603.24(b)(1)(x)
§603.24(b)(1)(xi) §603.24(b)(1)(xii) §603.24(b)(2)(i)
§603.24(b)(2)(ii) §603.24(b)(2)(iii) §603.24(b)(2)(iv)
§603.24(b)(2)(v) §603.24(b)(2)(vi) §603.24(b)(2)(vii)
§603.24(c)(1) §603.24(c)(2) §603.24(c)(3)
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§603.24(c)(4) §603.24(d)(1) §603.24(d)(2)
The above listing of outstanding issues revealed that the agency is out of compliance with all but
five of the criteria for recognition. The issues of non-compliance are founded on the insufficient
narrative and documentation in the agency’s petition. The agency provided little detail of its
policies and procedures, for example about its functions, guidelines related to administrative and
program performance, the selection of on-site evaluation committees, the decision-making body,
and its grievance procedures. No documentation was provided to indicate the level of interaction
the agency has with its schools, and there was inadequate documentation of program reviews and
approvals.
The Committee’s extensive deliberation focused on
1. the ability of the agency to address the many significant compliance issues, and
2. a consideration of alternatives that may be available to the agency and its accredited
institutions i.e., transitioning the accreditation function to another accrediting body.
The Committee’s original motion was to recommend that the Puerto Rico State Agency’s
recognition be continued with a limitation to not recognize any new institutional/program
accreditations. This motion failed to receive a majority vote (4-7).
The Committee’s second motion was based on the Committee’s conclusion that there was
sufficient evidence that the agency could not reasonably be expected to bring itself into
compliance in a timely manner. The Committee recommended (9-2) that the agency's petition for
renewal of recognition be denied.
Written Materials Reviewed by the Committee: Petition and supporting documentation submitted
by the agency and the Department staff analysis.
NACIQI Primary Readers:
Dr. Arthur E. Keiser
Representatives of the Agency:
Dr. Helen Sosa Staples, Assistant Secretary for Career and Technical Education, Puerto Rico
Department of Education
Prof. Victor Cintron Feliciano, Assistant to the Assistant Secretary for Career and Technical
Education
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REQUESTS FOR DEGREE-GRANTING AUTHORITY BY FEDERAL INSTITUTIONS
I. Request by a Federal Institution for Authority to award a Degree
National Intelligence University (NIU)
Action for Consideration: Request for Degree-Granting Authority to award a Master of Science
and Technology Intelligence degree.
Committee Recommendation: Vote 11-0
The site team recommends that the NACIQI recommends to the Secretary that he recommend that
the University be granted degree-granting authority, as requested for Master of Science and
Technology Intelligence.
Further, the NACIQI wishes to make it clear that it is their intent that the graduating classes, 2011-
2012, are eligible to receive degrees if degree authority is granted even though Congress may not
act before the current class completes the course.
Comments: The Department of Education's authority to conduct reviews of degree-granting
requests by Federal institutions is contained in a policy statement entitled "Federal Policy
Governing the Granting of Academic Degrees by Federal Agencies and Institutions," which
specifies that the Secretary of Education appoint a Review Committee to examine applicant
federal programs and determine compliance with four criteria. The National Advisory Committee
on Institutional Quality and Integrity (National Advisory Committee) serves as the Review
Committee designated in the policy statement.
The NIU is seeking authority to grant a Master of Science and Technology Intelligence that the
University has developed in response to the Department of Defense Instruction DODI-3305.01
dated December 22, 2006, incorporating change 1 of February 9, 2011. On April 3, 2012, a site
team from the National Advisory Committee on Institutional Quality and Integrity (NACIQI) and
the U.S. Department of Education conducted a visit to the Anthony G. Oettinger School of
Science and Technology Intelligence (School of S&TI) within NIU. Following comprehensive
presentations by the site team Chair and the agency representatives, the Committee had no
questions prior to its vote on the motion.
NACIQI Site Visit Team:
Mr. Cameron Staples, J.D., Team Chair
Dr. Arthur E. Keiser
Dr. Carolyn G. Williams
Representatives of the Agency:
Dr. David Ellison, President, NIU
Dr. Susan Studds, Provost, NIU
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Dr. Brian Shaw, Dean School of Science and Technology, NIU
Dr. Duncan McGill, Associate Dean, School for Science and Technology Intelligence, NIU
N. John McGaffin, Board Member-NIU Board of Visitors